ML20211P835
| ML20211P835 | |
| Person / Time | |
|---|---|
| Site: | 07109268, 07201023 |
| Issue date: | 09/03/1999 |
| From: | Fuller E External (Affiliation Not Assigned) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20138D213 | List: |
| References | |
| BFS-NRC-99-083, SNC-109, SNC-209, NUDOCS 9909140119 | |
| Download: ML20211P835 (50) | |
Text
Q). Q2(oS 9BNFL
)
BNFL Full Solutions Corporation 1 Victor Square Fuel Solutions Scotts Valley, CA 95066 rei; <8333 438 3444 Fax: (831) 438-5206 September 3,1999 BFS/NRC 99-083 Docket Nos. 71-9268,72-1023 File Nos. SNC-109, SNC-209 Director, Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
Re-submittal of Responses to NRC Questions Regarding the TranStor" Shipping Cask System
References:
- 1) BFS Letter, Responses to NRC Questions Regarding the TranStor" Shipping Cask System, BFS/NRC 99-077, dated August 7,1999
Dear Sir,
In Reference 1, BNFL Fuel Solutions (BFS) responded to the 31 NRC questions regarding the TranStor Part 71 application. As discussed with the NRC Project Manager, Mr. Tim Kobetz, BFS has discovered administrative errors in that submittal, and therefore requests that it be withdrawn. The enclosure hereto provides the re-submittal, including all necessary corrections, ofits responses to the NRC questions, including the corresponding revisions to the TranStor Part 71 Safety Analysis Report (SAR), SAR drawings, and supporting calculations.
BFS has infonned Mr. Tim Kobetz that the'Part 72 application is affected by the enclosed responses to the 31 NRC questions. BFS will provide a revision to the Part 72 application incorporating the effects of the Part 71 changes in the near future.
BFS has minimized the labeling of technical information as proprietary. However, there j
remains information that BFS considers commercially sensitive and as such is held in
/
confidence. Specifically, the enclosures contain the following proprietary infonnation:
I j
SAR drawings and supporting calculations. BFS requests that the NRC withhold this
/
information from public disclosure pursuant to 10CFR2.790. Additionally, the enclosures provide redacted versions of the affected documents and the affidavits r
documenting the propr{ep basis for the documents.
h I
The commitments made in this submittal are documented on page 3.
H< al.
/; /
p/gg & - [g
) JL-9909140119 990903 PDR ADOCK 07109268 f
B PDR d
n US Nuclear Regulatory Commission BFS/NRC 99-083 Page 2 If there are any questions, please contact Wayne Massie at (408) 438-6444.
Sincerely, E.
. Fuller President & CEO Enclosures cc)
Mr. L.G. Dusek Ms. Marilyn Meigs Portland General Electric BNFL Inc.
71760 Columbia River Hwy.
600 New Hampshire Ave NW, Suite #1200 Rainier, OR 97048 Washington DC 20037 Mr. Dan Gildow Mr. Max DeLong Portland General Electric Project Engineer 71760 Columbia River Hwy.
Private Fuel Storage, LLC Rainier, OR 97048 c/o NSP,512 Nicollet Mall Minneapolis, MN 55401 Mr. John Broschak Mr. John Donnell Consumers Energy Stone & Webster Palisades Nuclear Plant 7677 E. Berry Ave.
27780 Blue Star Memorial Hwy.
Englewood, CO 80111-2137 Covert, MI 49043-0930 Mr. Steve Guthrie Consumers Energy Big Rock Point 10269 U.S. 31 North Charlevoix, MI 49720 -
x
US Nuclear Regulatory Commission BFS/NRC 99-083 Page 3 i,lST OF COMMITMENTS 99-083-01 BFS will provide the changes in the Part 72 application resulting fmm the enclosed Past 71 submittal in the near future.
'99-083-02 The next revision of the Coatings Qualification Report will include the discussion ofpeak excursion temperature testing. (From Question 6) 99-083-03 As a result of the preliminary evaluation of design calculations associated with the impact limiter test program, the calculations for the BWR basket require the use of Type 304. The revised calculations will be issued with the submittal of the Impact Limiter Test Report by September 30,1999.
(From Question 12) 99-083-04 The next revision of the Coatings Qualification Report will incorporate the boric acid test information. (From Question 16)
'99-083-05 The revision of the Coatings Qualification Report will delete the phrase "1200F vs. 520F."(From Question 19) 99-083-06 The next revision of the Coatings Qualification Report will describe the radiation exposure test. (From Question 20)
C J
US Nuclear Regulatory Commission BFS/NRC 99-083 Page 4 STATE OF CALIFORNIA COUNTY OF SANTA CRUZ E. D. Fuller states that he is the President and Chief Executive Officer of BNFL Fuel Solutions; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
A E. D. Fuller President and Chief Executive Officer BNFL Fuel Solutions Corporation Sworn to and subscribed before me this bd day o QN\\h t\\_,
1999,by Y\\uacM i
Notary Public, State of CalifBmia j
SHAUN DINAPOU COMM. #1143410 Notary Public-Californla Santa Cruz County w
My Comm.Exp. July 25,2001 - [
g g
~
(Print, type, or stamp Comhiissioned
~
Name of Notary Public)
Personally Produced Known OR Identification U
d
LIST OF ENCLOSURES ENCLOSURE 1 AFFIDAVIT FOR SAR DRAWINGS ENCLOSURE 2 AFFIDAVIT FOR DESIGN CALCULATIONS i
ENCLOSURE 3 RESPONSES TO TIIE 31 NRC QUESTIONS ENCLOSURE 4 LIST OF CIIANGES FOR SAFETY ANALYSIS REPORT, REVISION C ENCLOSURE 5 REPLACEMENT PAGES FOR SAFETY ANALYSIS REPORT, REVISION C (REDACTED /NON-PROPRIETARY)
ENCLOSURE 6 SAFETY ANALYSIS REPORT, APPENDIX A REPLACEMENT PAGES (PROPRIETARY)
ENCLOSURE 7 PROPRIETARY CALCULATIONS ENCLOSURE 8 REDACTED /NON-PROPRIETARY CALCULATIONS ENCLOSURE 9 REPLACEMENT PAGES FOR VOLUME IV, TAB 7 TABLE 1 COMPLIANCE MATRIX TO NUREG-1617 k,
b
US Nuclear Regulatory Commission BFS/NRC 99-083, Enclosure 1 Page1 TranStor Part 71 Shipping Cask System AFFIDAVIT IN SUPPORT OF PROPRIETARY INFORMATION CONTAINED IN BNFL FUEL SOLUTIONS DRAWINGS State of Califomia, County of Santa Cruz 4
1, E. D. Fuller, being duly swom, depose and state as follows:
(1) I am the President and Chief Executive Officer of BNFL Fuel Solutions ("BFS") and have been delegated the function of reviewing the information described in paragraph (2), which is sought to be withheld, and have been authorized to apply for its withholding.
(2) TSc information sought to be withheld is contained in the design drawings listed below. The proprietary material in these documents is delineated by proprietary designation on specific pages or within specific sections of the pages.
SAR-71-002, Sheet I/6, Rev. 2 S AR-71-003, Sheet 1/2, Rev.1 SAR-71-004, Sheet 1/8, Rev. I SAR-71-005, Sheet 1/12, Rev. 2 (3) In making this application for withholding of proprietary information of which it is the owner, BFS relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 U.S.C.
552(b)(4), and the Trade Secrets Act,18 U.S.C. { 1905, and NRC regulations 10 C.F.R. @ 9.17(a)(4),2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential."(" Exemption 4"). The material for which exemption from disclosure is here sought is all" confidential commercial information," and some portions also qualify under the narrower definition of" trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption
- 4. See Critical Mass Encrev Project v. NRC,975 F.2d 871 (D.C. Cir.1992), cert.
denied,507 U.S. 984 (1993); Public Citizen Health Research Group v. FDA,704 F.2d 1280 (D.C. Cir.1983),
(4) Information that is held in confidence, meaning if the information is released, it might result in the loss of an existing or potential competitive advantage, falls into one or more of the following category types:
)
US Nuclear Regulatory Commission BFS/NRC 99-083, Enclosure 1 Page 2 (a) The information reveals the distinguishing aspects of components, and the prevention ofits use by BFS's competitors, without license from BFS, gives BFS a competitive economic advanta;;e.
(b) The information, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
(c) The information reveals aspects of past, present, or future BFS or customer funded development plans and programs of potential commercial value to BFS.
(d) The information contains patentable ideas, for which patent protection may be desirable.
(5) The infomiation sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by BFS, and is in fact so held.
The information sought to be withheld has to the best of my knowledge and belief, consistently been held in confidence by BFS, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements that provide for maintenance of the information in confidence.
(6) The procedure for approval of extemal release of such a document typically requires review by the project manager, lead technical and management personnel, and by the licensing manager, for technical content, compctitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside BFS are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(7) The information identified in paragraph (2) is classified as proprietary because:
(i)
It contains detailed results of analytical models, computer codes, methods and processes, in which BFS has a proprietary interest and has applied to evaluations of the TranStor Part 71 shipping cask system for which BFS is seeking NRC approval.
(ii)
The development and eventual approval of the designs represented in these documents was achieved at a significant cost to BFS.
(iii)
The interpretation and application of analytical results is derived from the extensive experience database that constitutes a major BFS asset.
)
US Nuclear Regulatory Commission BFS/NRC 99-083, Enclosure 1 Page 3 (iv)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to BFS's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of BFS's technology base and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the analytical methodology and includes development of the expertise to determine and apply appropriate evaluation process. In addition, the technology base includes the value derived from NRC's eventual approval of the specific cask design.
(v)
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by BFS.
(vi)
BFS's competitive advantage will be lost ifits competitors are able to use
{
the results of the BFS experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating j
that they can arrive at the same or similar conclusions.
(vii)
The value of this information to BFS would be lost if the information were
]
disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive BFS of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment.
l 1
~)
J
(
E. D. Fuller BNFL Fuel Solutions Sworn to before me this bck day ofkd2mht A 1999.
t d
SHAUN DINAPOU l
Notary Public,'Siale ofdalifomia COMM #114B410 Notary PuNic-C#;rnia Santa Cruz County w
??--
U.S. Nuclear Regulatory Commission BFS/NRC 99-083, Enclosure 2 Page1 TranStorm Part 71 Shipping Cask System AFFIDAVIT IN SUPPORT OF PROPRIETARY INFORMATION CONTAINED IN BNFL FUEL SOLUTIONS CALCULATIONS State of California, County of Santa Cruz I, E. D. Fuller, being duly sworn, depose and state as follows:
(1)
I am the President and Chief Executive Officer of BNFL Fuel Solutions ("BFS")
and have been delegated the function of reviewing the infomiation described in paragraph (2), which is sought to be withheld, and have been authorized to apply for its withholding.
(2)
The information sought to be withheld is contained in the calculations listed below. The proprietary material in these documents is delineated by proprietary designation on specific pages or within specific sections of the pages.
BNFL 1.10.06.14, Revision 6 BNFL 1.10.06.15, Revision 4 i
(3) In making this application for withholding of proprietary information of which it is the owner, BFS relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 U.S.C.
552(b)(4), and the Trade Secrets Act,18 U.S.C. @ 1905, and NRC regulations 10 C.F.R. 9.17(a)(4),2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential."(" Exemption 4"). The material for which exemption from disclosure is here sought is all " confidential commercial information," and some portions also qualify under the narrower definition of" trade
)
secret," within the meanings assigned to those terms for purposes of FOIA Exemption
- 4. _S_ee Critical Mass Eneruv Project v. NRC,975 F.2d 871 (D.C. Cir.1992), cert.
denied,507 U.S. 984 (1993); Public Citi7en Heath Research Groun v. FDA,704 F.2d 1280 (D.C. Cir.1983).
(4) Information that is held in confidence, meaning if the infonnation is released, it might result in the loss of an existing or potential competitive advantage, falls into one or more of the following category types:
(a) The information reveals the distinguishing aspects of components and the supporting evaluation processes and test methodologies, and the prevention of its use by BFS's competitors, without license from BFS, gives BFS a competitive economic advantage.
i
r U.S. Nuclear Regulatory Cor.imission BFS/NRC 99-083, Enclosure 2 Page 2 (b) The information, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
(c) The information reveals aspects of past, present, or future BFS or customer funded development plans and programs of potential commercial value to BFS.
(d) The information contains patentable ideas, for which patent protection may be desirable.
(5) The information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by BFS, and is in fact so held.
The information sought to be withheld has to the best of my knowledge and belief, consistently been held in confidence by BFS, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements that provide for maintenance of the information in confidence.
(6) The procedure for approval of extemal release of such a document typically requires review by the project manager, lead technical or management personnel, and by the
]
licensing manager, for technical content, competitive effect, and detemiination of the accuracy of the proprietary designation. Disclosures outside BFS are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(7) The information identified in paragraph (2) is classified as proprietary because:
(i)
It contains detailed results of analytical models, computer codes, methods and processes, in which BFS has a proprietary interest and has applied to j
the evaluations of the TranStor shipping cask system for which BFS is seeking NRC approval.
(ii)
The development and eventual approval of designs and evaluation methodologies used in the calculation were achieved at a significant cost to BFS.
(iii)
The evaluation process and/or the test methodology along with the interpretation and application of the analytical results are derived from the extensive experience database that constitutes a major BFS asset.
Individual equations or numerical values contained in the listed calculations may be available in the public domain. However, the request 4
U.S. Nuclear Regulatory Commission BFS/NRC 99-083, Enclosure 2 Page 3 to withhold the listed calculations is not based on an individual equation or numerical value, but is based on the application of BFS's methodology using the equation and numerical value as it is integrated within the design calculations and taken as a whole.
(iv)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to BFS's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of BFS's technology base and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the analytical methodology and includes development of the expertise to determine and apply appropriate evaluation process. In addition, the technology base includes the value derived from NRC's approval of the specific cask design.
(v)
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by BFS.
(vi)
BFS's competitive advantage will be lost ifits competitors are able to use the results of the BFS experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
4 (vii)
The value of this infonnation to BFS would be lost if the infonnation were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive BFS of the opportunity to exercise its competitive advantage to seek an adequate return on its la'de investment.
E. D. Fulle,r &
>?,
0 BNFL Fuel Solutions Sworn to before me this brd day ofMd%hm 1999.
\\
A A.148410 AM NN Bl e*
"Eg' "*
Notary PubNc'Sthte of Califomia My Comm. Exp. July 2 20 9 _ _. l
<l SHAUN DiNAPOLI COMM. #1148410 L
MyComm Exp July 25,20 Notary Pubk-Cahfornia Santa Cruz County w
B ENCLOSURE 3 RESPONSES TO TIIE 31 NRC QUESTIONS
. l BNFL Fuel Solutions BFS/NRC 99-083. Enclosure 3 Thermal QUESTION:
1)
Drawing CA-001 Sheet 1B, Note 21, relates to chromium plating. How was chromium plating addressed in the design calculations and assumptions?
RESPONSE
Note 21 on Drawing CA-001, Sheet 1 of 3, Revision 3, pertains to the 60 Socket Head Bolts that secure the Closure Lid to the Top Forging Assembly of the Shipping Cask. A similar note is on Drawing SAR-71-002, sheet 1 of 6, Note 18.
The notes direct that these bolts have a 0.0002" to 0.0005" thick chrome electroplate surface. This very thin surface provides a hard, wear-resistant and corrosion-resistant surface finish. These bolts are located at the end of the shipping cask near the outer periphery where conduction heat transfer and temperatures are relatively low. Therefore, this chrome plate material is neglected in the thermal model, and is not required to perform a critical safety function. The region is modeled using the predominant 304 stainless steel material used for the Closure Lid and the Top Forging.
i 2
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
2)
Allowable manufacturing dimensions: Discuss any changes in dimensional gaps and the integration ofsuch changes into the design calculations.
RESPONSE
The variable distribution of gaps is the result of component tolerances. Gaps between the components, however, present barriers for heat flow and affect maximum calculated fuel temperature.
The BWR basket is assembled such that gaps between the fuel cells are minimized, which improves the thermal perfomiance of the system. The edge assemblies (spacers 1 and 2) are adjusted to maintain predetermined gaps of different sizes across the sleeve stacks (Note 18 of Drawing TSB-001, Sheet 1 of 6, Revision 3). The gaps are sized to allow free thermal expansion of the sleeves and to be completely closed for the full heat load basket in the vacuum-dried condition. This provides maximum thermal contact for that most limiting configuration (Calculation BNFLI.10.06.48, Revision 2).
Although it is expected that most of the cells will be in contact, no credit is taken for the contact between the cells after the basket is filled with Helium. The effective conductivity of the Boral poison plates is determined by assuming 0.01 inch gaps (throughout the BWR basket) between the poison sheet and the adjacent cell (s). The calculation results are conservative, since the basket components, in reality, are expected to be in panial contact.
For the PWR design, the model used for the analysis in calculation BNFLI.10.06.21, Revision 3, assumes gaps at any location between two unconnected components. A gap sensitivity study was performed for the cask storage model (Calculation TSL01.10.06.35, Revision 1) that applies to the cask shipping model (Calculation BNFLI.10.06.21, Revision 3), since the analytical model is the same. The results of this study demonstrate that the gap distribution used in the storage cask analysis produces a higher temperature than if the unconnected components were in contact. The calculation results are conservative, since the basket components, in reality, are expected to be in partial contact.
3
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
- 3).
Use ofANSYS Code: Which version ofANSYS was used (i.e., version 5.0 or 5.4)?
Discuss the different methods ofnodalization that were utilized.
RESPONSE
ANSYS Version 5.5 was used for Calculation BNFLI.10.06.22, Revision 2.
ANSYS Version 5.4 was used for Calculations BNFLI.10.06.21, Revision 3, and BNFLI.10.06.48, Revision 2. Automatic nodalization and mesh generation were used for both 3D (axisymmetrical) and 2D analysis. There is no difference between nodalization and mesh generation for these models using either Version 5.4 or 5.5 of ANSYS.
4
-r.
BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 3
. QUESTION:
4)
Maximum cladding oxide thickness layer: Confirm the valuefor the maximum thickness layerfor the cladding at temperature limit.
RESPONSE
The maximum oxide layer thickness is 2.5 mils (the diametrical oxide layer of 5 mils divided by 2), per PNL-4835, " Technical Basis for Storage of Zircaloy-Clad Spent Fuel Rods in Inert Gases," Pacific Northwest Laboratory, May 1983.
I 5
BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
5)
Emissivity values: The tables in the SAR provide emissivity valuesfor stainless steel at 400*F. Discuss how emissivity values were used in the design calculationsfor shell temperature (which equaled 211*F). How was conservatism incorporated?
RESPONSE
The presentation of the emissivity value for stainless steel in SAR Table 3.2-1 was intended to indicate that a constant value is used across the temperature range shown in the table. The emissivity value for stainless steel used in the design calculations (BNFLI.10.06.21, Revision 3, BNFLI.10.06.22, Revision 2, and BNFLI.10.06.48, Revision 2) is 0.48 across the applicable temperature range.
The emissivity values used in the design calculation are selected to be equal to or lower than the lower bound of the emissivities. These low emissivity values are conservatively used, without temperature dependence, for the entire applicable range of temperatures. The low emissivity values produce low thermal conductance values that lead to conservatively higher internal temperatures.
SAR Tables 3.2-1 through 3.2-5 and 3.2-7 have been clarified.
i 6
n.
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
6)
Section 3.3.7 ofthe SAR: Thepeak excursion temperature was noted to be 530*F for.f.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Was this parameter evaluated in the coatings report? Ifit wasn 't, why not? Ifit was, discuss the enluation..
RESPONSE
The coating qualification testing addressed the peak excursion temperature and duration as documented in Reference 6.9 of the Coatings Qualification Report, Revision 2. The test coupons were held in a test chamber that was heated to 530*F (* 10*F) for a period of 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. On completion of the test, system cool-down and sampling of the test gases, the specimen was removed from the test chamber, weighed to an accuracy of
- 0.01 gram, and visually inspected for the potential coating defects listed below:
Checking-ASTM Method D 660 e
o' Cracking-ASTM Method D 661 Blistering-ASTM Method D 714 Flaking-ASTM Method D 772 Delamination - No guidance necessary Peeling-No guidance necessary
. Unusual appearance - No guidance necessary No ASTM paint failures were observed. In addition, except for a minor scratch that did not penetrate the coating to base metal, no delamination, peeling, or other unusual appearances were observed. The next revision of the Coatings Qualification Report will include the above discussion of peak excursion temperature testing.
7
BNFL Fu:1 Solutions BFS/NRC 99-083 Enclosure 3 Materials QUESTION:
7)
Section 3.3.4 ofSAR (pg. 3-18): BFS takes exception to the ASME Code relative to temperature limit excursion. I17:at is the impact oftemperature limit excursion on plastic deformation limits?
RESPONSE
As discussed with the NRC on June 11,1999, the ASME Boiler and Pressure Vessel Code (SAR Reference 3.32) permits a maximum operating temperature of 800 F for stainless steel when used for stmetural purposes. As shown in the TranStor thermal analysis Calculation BNFLI.10.06.22, Revision 2, the only time that this temperature may be exceeded is when the TranStor" Shipping Cask package is exposed to a 1475 F fire for 30 minutes, as specified in 10 CFR 71.73(c)(4).
Per SAR Table 2.10.1-8, the maximum internal pressure stress during the worst conditions (including the hypothetical accident fire)is 1.89 ksi. ASME Code Case N-47 provides the design-allowable stress limits for stainless steel at elevated temperatures for limited periods. For the period of 10 hrs at 1500 F, Sm is 5.3 ksi. Therefore, no plastic defomiation will occur.
Carbon steel is used in the neutron shield cooling fins and skin. Although the ASME Boiler and Pressure Vessel Code permits a maximum operating temperature of only 700 F, this material performs no structural function during or afler the hypothetical accident condition (HAC) fire. Since the melting temperature of this material is above 2500 F, the material would stay in place throughout this event.
Section 3.3.4 of the TranStor Part 71 SAR has been revised accordingly.
8 i
7 BNFL Fu:1 Solutions
- BFS/NRC 99-083, Enclosure 3 QUESTION:
8)
Section 8.M.3 ofSAR (pg. 8-7): BFS discusses initial acceptance conditions of the impact limiter components. Discuss periodic inspection requirements ofthe
' assemblies and address the assurance that no degradation will occur in service
' due to weather, corrosion, etc. Is the assembly sealed, breathable, or open? '
RESPONSE
The TranStor impact limiter is constructed of an aluminum honeycomb core enclosed by a stainless steel exterior. The joints and seams of the exterior are welded to provide a sealed unit; thus no degradation affecting the impact limiter's intended function would occur due to weather and corrosion. All enclosure welds are subjected to visual and liquid penetrant inspection during fabrication to ensure that the impact limiter is sealed. Section 8.1.4.3 of the TranStor Part 71 SAR has been revised accordingly.-
In addition, SAR Section 8.2.7 has been revised as follows:
"The impact limiters are visually inspected prior to each shipment. Any deformation at any location greater than one inch when compared to the nominal dimensions presented in the SAR drawing, or any cracks, holes, punctures, broken welds, or broken or defective attachment lugs will be repaired. Any affected honeycomb will be filled or replaced with identical material. The stainless steel casing will be straightened or replaced and resealed.
"After one year of service and at five-year intervals thereafter, the impact limiter welds shall be subjected to visual and liquid penetrant inspection to the same requirements as initial fabrication."
9
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
9)
Drawing SAR-71-002 Sheet 1, Note 10, indicates that all other welds are made in accordance with ASME Section IX. However, Section IXis not a construction
\\
code. Therefore, provide a reference to the appropriate article in ASME Section 111or to another construction code, j
)
RESPONSE
As discussed with the NRC on June 11,1999, BFS agrees with this comment.
Drawing SAR-71-002 Sheet 1, Note 10 has been revised to read as follows:
"10. ALL WELDS ON CONTAINMENT BOUNDARY SHALL BE IN.
ACCORDANCE WITH ASME SECTION III, NB-4400. ALL OTHER STRUCTURAL WELDS TO BE IN ACCORDANCE WITH ASME l
SECTION III, NF-4400." CETIFICATE HOLDERS AND AUTHORIZED NUCLEAR INSPECTORS, AS REFERENCED IN NB/NC/NF/NG-4000, ARE NOT USED.
Additionally, a new Section 2.1.2.4 has been added to the TranStor Part 71 SAR to clarify the fabrication requirements.
I 1
10 l
- 1 t
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
10)
Different materials used in construction: Provide a schedule ofplier material typesfor corresponding base metals.
i i
RESPONSE
As discussed with the NRC on June 11,1999, BFS does not specify a filler material for each base metal. Rather, filler materials are selected by the BFS fabrication contractor and become a part of the Welding Procedure Specification (WPS). The WPS using these filler metals is qualified in accordance with the applicable ASME Code Subsection. All WPSs and the Procedure Qualification Records (PQRs) are appmved by BFS prior to use.
Filler materials are normally selected to provide the same nominal chemical composition as either or both of the base metals beingjoined. In addition, filler metals must provide tensile strength, in the as-welded condition, equal to or j
exceeding that of either or both of the base materials being joined.
The following table shows some typical acceptable filler materials:
I Material types Welding Process to be joined GTAW SMAW
)
304 to 304 ER308 E308 304L to 304L ER308L E308L XM-19 to XM-19 ER209 E209 304 to XM-19 ER308L E308L XM-19 to 630 ER309 + ER209 E309 + E209 A 36 to A 36 ER70S-2 E7018 A 36 to XM-19 ER309 E309 A 588 to A 588 ER70S-2 ER70S-6 11
. BNFL Fuel Solutions
- BFS/NRC 99-083, Enclosure 3 QUESTION:
11)
Welding: Drawing SAR-71-003 Sheet 1, Notes 1 and 2, references A WS D1.1 Codefor welding. This code reference is not mentioned in the SAR as applicable for construction, ifinvoked, it is not applicablefor welding stainless steel.
Clanfy this discrepancy and venfy that references to applicable welding codes, including exceptions, in the SAR are correct.
RESPONSE
As discussed with the NRC on June 11,1999, BFS agrees with this comment.
Drawing SAR-71-003 Sheet 1, Notes 1 and 2, have been revised to read as follows:
"1. ALL STRUCTUPAL WEI.DS SIIALL BE IN ACCORDANCE WITH ASME SECTION III, NP-4400.
In addition, Section 2.1.2.4 has been added to the TranStorm Part 71 SAR as presented in the response to Question 9 above and SAR Reference 2.11 (i.e.,
ANSI /AWS D1.1-88) has been deleted.
12
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
12)
Drawing SAR-71-004 and others: Varying grades ofstainless steel with differing mechanicalproperties are used in construction. No discussion is provided regarding the efects ofvariation in materialproperties on structural design.
Discuss the effects ofdiferent strengths, weld material requirements, and critical flaw size allowances.
RESPONSE
SAR Section 2.3.1, Revision A, states," Primary structural components of the TranStor Shipping Cask are made of stainless steel and components of the TranStor basket are designed to be fabricated of stainless steel (shell) and carbon steel (intemals). The specific materials used for the system components, including fasteners, are shown in the Chapter 1.0 drawings. Whem the options exist, the structural evaluations use the bounding properties and allowable stresses."
The last sentence of this paragraph is intended to state that, where options exist to utilize varying material grades, the structural calculations are always based on the material that will provide the most conservative design. Currently, the design of the BWR and PWR baskets are based on using Type 304L austenitic stainless steel, which has conservative material properties compared with Type 304. As a result of the preliminary evaluation of design calculations associated with the impact limiter test program, the calculations for the BWR basket require the use of Type 304. The revised calculations will be issued with the submittal of the Impact Limiter Test Report by September 30,1999.
Therefore, use of any of the specified materials in any location is bounded by the stmetural analyses. Where use of either Type 304 or 304L austenitic stainless steel is allowed by the design, it is our intent to consistently use the same grade throughout any one canister.
Weld materials are typically applied as described in the response to Question 10, above. That is, for Type 304L base materials, Type E/ER 308L filler materials are typically used, and for Type 304 base materials, Type E/ER 308 filler materials are typically used. Except as described above for the BWR basket, both filler material classifications are enveloped by the design.
The requirement for determination of critical flaw sizes in austenitic stainless steels has been removed by Revision 1 ofISG-4. Therefore, critical flaw sizes in these materials are not relevant.
SAR Section 2.3.1 has been revised to delete the phrase,"Where options exist,",
13
BNFL Fuel Solutions i
BFS/NRC 99-083, Enclosure 3 QUESTION:
13)
' Drawing SAR-71-005 Note 2 relates to penetrant test intervalsfor criticalfaw size. No basis isprovidedfor thisparameter. Was this basisprovided with the Part 72 Storage application? Ifso, there is no need to re-submit itfor Part 71.
RESPONSE
The requirement for determination of critical flaw sizes in austenitic stainless steels has been removed by Revision 1 ofISG-4. Therefore, critical flaw sizes in these materials are not relevant. Drawing SAR-71-005, sheet 1 of 12, Note 2, has been revised to read:
"2. PERFORM PT OF ROOT LAYER, ONE-HALF OF TiiE WELDED JOINT TIIICKNESS, AND FINAL SURFACE."
1 Drawing SAR-71-004, sheet 1 of 8, Note 1, has also been revised.
l 14
BNFL Fuel Solutions BFS/NRC 99-083. Enclosure 3 QUESTION:
14)
Cell assembly material A-500 Carbon Steel: ASTM Note I warns that this material may not be suitable where low temperature notch toughnes: properties are important. Given this caution, what damage to the cells can be anticipated following a drop accident?
RESPONSE
As discussed with the NRC on June 11,1999, the design and construction of the fuel support assemblies are consistent with the requirements of ASME Section III, Subsection NG. NG-2300 exempts materials less than 5/8 inches thick because all permitted materials are expected to have adequate toughness in that thickness range. While A-500 has not been adopted for NG construction, it is permitted for NF constmetion, which has the same exemption.
i 15
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
15)
A-588 is a high strength, low alloy material: What are theplier material and preheat requirements? Consider impact test resuta andlow temperature properties in your response.
l RESPONSE:
Regarding filler materials, refer to the response to Question 10, above.
Minimum preheat is typically 200'F, unless post-weld heat treatment is to be
. applied. Impact testing is not required because ASME Section III, NG-2300 exempts materials less than 5/8 inches thick (all pennitted materials are expected to have adequate toughness in that thickness range). A-588 typically provides sufficient fracture toughness in any thickness.
1 I
16 j
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
16)
Coatings report and boric acid tolerance at elevated temperatures: How long was the materialheldat 211*F?
RESPONSE
The Boric Acid tolerance tests at elevated temperatures were performed according to Evaluation of Coated Specimens in Boric Acid Solution at Elevated Temperatures, Procedure No. I807, Revision 2. Figure 4-3 (attached) of l
Appendix 6.4 in the Coatings Qualification Report, Revision 2, shows the temperature profile (history) for the test specimens. This figure shows that the samples were held above 200 F for 280 minutes, and held at/or above 210 F for about 110 minutes.
The Coatings Qualibcation Report will be revised to include the above information.
l 1
17 1
BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 3 j
Figure goes here.
l 18
m BNFL Fust Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
17)
Coatings report, pg. 2.1.4, discusses the calculation ofneutron exposure. Did the radiation test include neutron exposure? Ifso. include a discussion in the report.
ifnot, why not.
RESPONSE
As stated in BFS's response to NRC RAl-2, Question l 1, for the TranStor Part 72 application, the radiation test did not include neutron exposure. The total 7
l neutron dose is conservatively estimated to be 1.0x10 Rads over the basket j
lifetime of 50 years. The total gamma dose for the basket coatings is conservatively estimated to be 1.15x10' Rads over the basket lifetime of 50 years. Since the total gamma dose is three orders of magnitude greater than the total neutron dose, the neutron flux does not contribute significantly to the total coating radiation exposure. Therefore, the coating qualification included a I
gamma radiation at 1.2x10' Rads.
l l
l l
l 19
BNFL FuelSolutions BFS/NRC 99-083, Enclosure 3 QUESTION:
18)
Coatings report, Section 2.3.3 concluded that radiolytic decompositionfor inorganics was notprovided. Give the basisfor this conclusion.
RESPONSE
Section 2.3.3 of the Coatings Qualification Report, Revision 2, states that a radiolytic decomposition evalua' ion of the interior coating was not required. The basis for this statement is that the two selected interior coatings, described in Section 3.1.1 of the coatings report, have completely inorganic binder systems -
and contain no volatile organic compounds (VOCs).
Further, the focus of NRC Information Notice 84-72 is radiolytically-generated combustible gases based on the absorbed dose and known properties of the water / organic substance. Since the two selected interior coatings do not contain organic materials, a radiolytic decomposition evaluation was not necessary.
l I
20
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
19)
Coatings report, pg. 2.3.4: Clarify the meaning of"hypotheticalfire accidents " of 1200*Fand 520*F.
RESPONSE
Section 2.3.4 of the Coatings Qualification Report, Revision 2, states that,"The coatings used on the basket internals are both inorganic materials with service temperatures well in excess of the temperatures the basket will see in a hypothetical fire accident 1200F vs. 520F." Section 3.5 of the TranStor Part 71 SAR describes the hypothetical accident thermal evaluation. In summary, the TranStor Shipping Cask package is modeled to be exposed to a 1475'F fire for 30 minutes, as specified in 10 CFR 71.73(c)(4). The maximum component temperatures during the HAC fire transient and the 40-hour cool-down period are listed in SAR Table 3.5-1.
l The next revision of the Coatings Qualification Report will delete the phrase "1200F vs. 520F."
1 21
[
. \\
. BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 3
[
QUESTION:
20)
Coatings report: Provide the details ofthe radiation exposure test.
RESPONSE
l Irradiation took place in a high flux facility that consisted of a container located between spent fuel elements. These elements completely surrounded the i
container to provide a uniform gamma radiation field. The samples were flushed l
by air during the irradiation.
Measurements of dose rate and temperature were taken prior to the start of the irradiation, and repeated three times at intervals of one day and one hour, in order l
to identify possible variations. The irradiation conditions were as follows:
Internal Basket External Basket Coating Coating Dose rate 0.075 - 0.032 MGy/hr 0.075-0.032 MGy/hr Irradiation duration 74 days 17 days Total dose collected 124.4 Mgy 20 MGy -
Irradiation 35"C, on average 35 C, on average temperature The specimens were subjected to the same dose rate. Deviation inside the entire radiation field was less than 7%. The maximum temperature deviation inside the radiation field was
- 4"C.
Examination of painted surfaces was carried out according to the following I
standards:
ASTM Standards D 659 Method of Evaluating Degree of Chalking of Exterior Paints l
D 660 Test Method for Evaluating Degree of Checking of Exterior Paints e
D 661 Test Method for Evaluating Degree of Cracking of Exterior Paints e
D 714 Test Method for Evaluating Degree of Blistering of Paints e
D 772 Test Method for Evaluating Degree of Flaking of Exterior Paints l
e Surfaces were observed by using an optical microscope (X10) and recorded on video. Pictures obtained for each specimen were compared with the photographic reference included in the standards. Visual inspection showed that the specimens successfully withstood the radiation exposure test.
The next revision of the Coatings Qualification Report will reflect the above
- description of the radiation exposure test.
I 22.
>+,
i
. 1 BNFL Fu:1 Solutions BFS/NRC 99-083. Enclosure 3 Containment QUESTION:-
21)
A shipping cask is not necessaryfor double containment given the limit of <20 curies ofplutonium. Explain how BFS will verify thisplutonium levelgiven measuring difficulties.
RESPONSE
Fuel debris consists of pellets that are lost from fuel cladding under the rare
' circumstance of gross failure. These failed assemblies are identified by assembly number and operating history, and the fuel pellets or debris from these assemblies
- can be quantified with respect to operating history. Debris that cannot be associated with a specific assembly (i.e., of unknown origin) can always be associated with a particular operating cycle since gross failures are well-documented. Debris of unknown origin can be assigned a conservative opgrating history (e.g., highest bumup of all failed assemblies in that cycle). Nucleat-utilities keep records of material inventories, including materials that may be in the form of fuel debris. Debris is specifically accounted for in utility records, but may be collected and stored in common receptacles in the reactor fuel pool.
The Initial Uranium gram-equivalent can be calculated by knowing the number of
' lost fuel pellets. Pellet loss can be determined by a physical count or by observing the extent of the cladding damage and estimating the missing pellets.
By combining this inventory with the known or inferred operating history of the pellets, the total plutonium inventory of the debris can be calculated on an isotope-by-isotope basis at the time of discharge. Subsequent calculations would determit e the decay between discharge and the time of storage and/or shipment.
The plutonium inventory is converted to activity units (curies) by multiplying each isotope mass by its specific activity. The sum of the plutonium activities must be less than 20 curies per basket consistent with SAR Section 1.2.4. All nuclear utilities have numerical methods that are routinely used to calculate uranium / plutonium isotopic inventories.
SAR Section 1.2.4 has been revised to require the documentation of the plutonium content. Such documentation would be consistent with the user's quality assurance program, and would require preparation, verification, and approval by qualified individuals.
23
BNFL Fu 1 Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
' 22)
Section 8.1.3.3 discusses theprocedureforpre-shipment leak testing around the ventport. Explain how the overallleak test accommodates thepre-shipment leak test and installation ofthe ventport.
RESPONSE
The steps in Section 8.1.3.3 were intended to explain that the vent port cavity should be enclosed, filled with helium at a slightly positive pressure, the cover plate bolted in place, and the leak-test performed. Steps 8 and 9 of SAR Section 8.1.3.3 have been revised to clarify this procedure.
The actual method to leak-test the vent port may vary between sites. However, as an example of how this process might be implemented, an inflatable bag with inlet and exhaust ports and provision for scaled manual access to its interior could be placed over the vent port and scaled to the cask lid with tape. The vent port cover plate and its attachment bolts would be within the bag. Helium would be supplied to the bag and the exhaust port would be monitored to ensure that a saturated helium atmosphere is achieved. A'small positive helium pressure would be maintained to ensure that there is no air entry to the bag. The pon cover would be installed and bolted in place via the manual access. The helium source would be disconnected and the bag removed from the port area. Then, Step 10 would be performed.
j i
24
BNFL Fuil Solutions BFS/NRC 99-083. Enclosure 3 QUESTION:
23)
Section 8.1.3.3 Step 3 appears to be in error. The discussion involves drawing a vacuum on the cask cavity then leak testing. This shouldread " draw vacuum on the space between the 0-rings, " then conduct the leak test. Discuss.
' RESPONSE:
BFS agrees with the comment. The final sentence in Step 3 is misplaced and should appear as the final sentence in Step 2. As corrected, Step 2 removes air from the cask cavity in preparation for the helium backfill and Step 3 performs the helium backfill. Step 4 (as written) draws a vacuum on the space between the O-Rings and monitors the leakage. Steps 2 an.13 of SAR Section 8.1.3.3 have been revised accordingly.
i 25 i
BNFL Fut! Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
24)
Section 8.1.3.2 Item 3: "1x10'" should be "1x10 "
RESPONSE
This is a typographical error. SAR Section 8.1.3.2 has been corrected.
i 4
I 26
BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
25)
Volume 4 RAIresponsepage 1: The title ofthe table is incorrect.
RESPONSE
The title of the table has been corrected to:" Table 1 - Compliance Matrix to
. NUREG-1617."
27
- BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 3 fl
QUESTION:
l 26)
Provide a SAR drawing that highlights the containment boundary.
RESPONSE
l l
SAR Figure 4.1-1 has been added to delineate the containment boundary provided by the shipping cask. SAR Section 4.1 has been revised to refer to Figure 4.1-1.
l I
28
P BNFL Fuel Soluti:ns BFS/NRC 99-083, Enclosure 3 Shieldine QUESTION:
27)
Basket length: The SAR indicates that basket length varies with thefuel type to be stored. Provide a table offuel types with corresponding basket lengths, specifying the size ofthe cask, the spacers, etc., to assure adequate coverage of poisonplates with activefuel.
RESPONSE
The length of the fuel assembly defines the minimum length of the basket.
However, the minimum basket length alone does not adequately ensure coverage of the active fuel by the poison plates. Rather, the length of the fuel sleeves and the poison plates relative to the basket cavity length ensures adeq6 ate coverage of the active fuel by the poison plates. Table 1 provides a typical schedule of basket cavity, fuel sleeve, and poison plate lengths for some BWR and PWR fuel assemblies.
The following methodology is used to detennine the lengths of the fuel sleeve and poison plate.
Fuel Sleeve Length The basket cavity length extends from the top of the basket bottom plate to the bottom of the shield lid. The basket cavity length is defined to accommodate the longest fuel assembly hardware (including inserted control components) after consideration of assembly irradiation growth, thermal expansion, and fabrication tolerances. The basket cavity length must be at least 0.5" longer than the longest fuel assembly hardware. The length of the fuel sleeve (CL) is then defined as the basket cavity length minus 1.5 i 0.5 inches.
As stated in the SAR, the maximum cavity length is 180 inches for a PWR basket and 175 inches for a BWR basket. Therefore, the maximum cell lengths are 178.5 i 0.5 inches and 173.5 i 0.5 inches for the PWR and BWR basket, respectively.
Poison Plate Length The poison plates in a PWR basket are attached so that they extend from the bottom of the fuel sleeve to within 4.25" of the fuel sleeve top. In a BWR basket, the poison plates are attached to the fuel sleeves such that they extend to within 2" of the fuel sleeve top and bottom.
29
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3
]
SAR Revision SAR drawings SAR-71-004, sheet 1 of 8, and SAR-71-005, sheet 1 of 12, have been revised to reflect the criteria for determining the length of the basket cavity and fuel sleeves.
An exception to this criteria is for the PWR baskets fabricated for Portland General Electric (PGE).
Revised calculation BNFLI.10.06.14, Revision 6, analyzed the most reactive Trojan fuel configuration to demonstrate that ker would not exceed 0.95 under any transportation HAC.
Table 1 -Typical Basket Lengths for Major BWP, and PWR Fuel Assemblies TranStor Fuel Assembly Typical Min. Basket Fuel Sleeve Canister Assembly Cavity LengM3) th.
Type Length Len h, CL BC gx2)
(in.)
(in.)
(in.)
BWR GE BWR/2-3 173.0 173.5 172.0 i 0.5 GE BWR/4-6 177.8 178.3 176.8 i 0.5 PWR B&W l5x15 (w/CC) 173.5 174.0 172.5 i 0.5 WE 15x15 162.7 163.2 161.7 0.5 N_o. tes:
(1)
All basket dimensions shown are typical and may vary slightly with different fuel types within each fuel assembly class.
(2)
BC > asse.mbly hardware + 0.5" (3)
CL = BC -(1.5" i 0.5")
1 i
I 30
BNFL Fu;l Soluti::ns BFS/NRC 99-083, Enclosure 3 QUESTION:
28)
Personnel barrier: Why is credit taken in the shielding evaluation, in spite ofthe demonstration that dose rates are less than 200 mrem /hr? There may be surface temperature considerations. Ifcredit is taken in the shielding evaluation, then provide datafor survivability during a drop accident.
RESPONSE: -
The radiation attenuation provided by the personnel barrier material was not included in the NCT shielding evaluation. Under normal conditions of transport (NCT), the shielding evaluation calculated the dose rates at locations corresponding to the outer surface of the personnel barrier. The calculated dose rates are less than 200 mrem /hr. The radiation attenuation provided by the personnel barrier material was not included in the NCT shielding evaluation.
For hypothetical accident conditions (HAC), attenuation of the personnel barrier material was also not included in the shielding evaluation. The calculated HAC dose rates are less than 1000 mrem /hr at I meter from the shipping cask outer shell.
SAR Section 5.3.1 has been revised to indicate that the attenuation provided by the personnel barrier was not considered in either the NCT or HAC shielding evaluations.-
31
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
29)
Forfuel types allowed, define theparameters. In Chapters 1 and 6 and in the calculation packages, consistency is not maintainedforparameters offuel types listed. Verify that the range ofparameters is bounding. Some applications use the middle ofthe range, while others use the most conservative. Check the criticality calculationsfor consistency.
RESPONSE
The PWR and BWR criticality analyses have been revised. For each assembly class, parameters important to criticality are explicitly defined. For parameters where allowable ranges are defined, the most reactive allowable value is used in the criticality analyses to detennine maximum allowable enrichment levels. For the remaining parameter range, sensitivity analyses are performed'to determine the most reactive allowable value.
The defined criticality parameters are taken from the criticality analyses and tabulated in Chapter 6 of the SAR. The fuel characteristics tables in Chapter 1 of the SAR have been removed and replaced with a reference to the Chapter 6 tables.
Thus, the criticality calculations and SAR chapters, as revised, are consistent.
32
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 i
Criticality QUESTION:
30)
Kegresults in calculation packages: Some valuesfor kegare above the upper safety limit. Clarify. Review all criticality calculationsfor similar conditions.
. RESPONSE:
As discussed in Question 29, the TranStor PWR and BWR criticality analyses were re-performed and the criticality analysis documents have been revised. The revised criticality cr.lculations used to determine maximum allowable enrichment levels produce final kerr alues (i.e., kerr + 20) that are under the limiting Upper v
Suberitical Limit (USL) values.
33
BNFL Fuel Solutions BFS/NRC 99-083, Enclosure 3 QUESTION:
31)
Figures 6.3.1 and 6.3.2 are unreadable asprovided. Review the SARfor legibility ofallfigures, tables, and drawingsfor similar conditions.
RESPONSE
A review of the SAR for legibility of all figures, tables, and drawings resulted in identification of the following items, including Figures 6.3.1 and 6.3.2, which were reproduced to be more legible:
Figure 2.5-1 Figure 2.7-2 e
Figure 2.10.1
- Figure 2.10.3-1 e
Figure 2.10.4-1 e
Figure 2.10.4-2 e
Figure 2.10.4-3 e
Figure 2.10.4-4 e
Figure 5.1-1 Figure 5.1-2 e
Figure 5.3-1 A e
Figure 5.3-1B e
Figure 5.3-2A e
Figure 5.3-2B e
i Figure 5.4-1 e
Figure 6.3-1 e
Figure 6.3-2 e
Figure 8.1-1 3
34
ENCLOSURE 4 LIST OF CIIANGES FOR SAFETY ANALYSIS REPORT, REVISION C j
l ENCLOSURE 4 TRANSTOR PART 71 SIIIPPING CASK SYSTEM SAFETY ANALYSIS REPORT, REVISION C LIST OF SAR CIIANGES Section / Table / Figure Description of Change Question Number Number Title page Revised to Revision C N/A Table of Contents Revised for consistency N/A List of Effective Pages Added to SAR N/A Section 1.1 Revised Definition of terminology N/A Section 1.2.4 Fuel characteristics tables were removed and the 29 section was updated to reflect the revised analysis in Chapter 6.
Drawing SAR-71-002, Note 10 has been revised to reference the 9
Sheet 1 of 6 applicable welding codes.
Drawing SAR-71-003, Notes 1 and 2 have been revised to reference the 11 Sheet 1 of 2 applicable welding codes.
Drawing SAR-71-004, Note I has been revised to reflect ISG-4, 13 + 27 j
Sheet 1 of 8 Revision 1, and the length of the cell and poison plates.
Drawing SAR-71-005, Note 1 has been revised to reflect ISG-4, 13 + 27 Sheet 1 of12 Revision 1, and the length of the cell and poison plates.
Section 2.1.2.4 A new section was added to define the fabrication 9 + 11 requirements.
Section 2.3.1 Clarified the application of the bounding material 12 properties used in stmetural evaluations.
Figure 2.5-1 Reproduced to be more legible.
31 Figure 2.7-2 Reproduced to be more legible.
31 Figure 2.10.1-8 Reproduced to be more legible.
31 Figure 2.10.3-1 Reproduced to be more legible.
31 Figure 2.10.4-1 Reproduced to be more legible.
31
~
l Figure 2.10.4-2 Reproduced to be more legible.
31 Figure 2.10.4-3 Reproduced to be more legible.
31 Figure 2.10.4-4 Reproduced to be more legible.
31
~
l Section 2.10.6 Reference 2.11 was deleted.
I1 l
Tables 3.2-1, 3.2-2, The temperature-independent properties were 5
3.2-3, 3.2-4, 3.2-5, clarified to remove confusion regarding use of the and 3.2-7 information in these tables.
Section 3.3.4 Clarified the impact of the hypothetical accident 7
condition fire.
I
- l BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 4 l
Section / Table / Figure Description of Change Question Number Number Section 4.1 Reference to Figure 4.1-1 added.
26 Figure 4.1-1 Added to delineate the containment boundary 26 provided by the shipping cask.
Figure 5.1-1 Reproduced to be more legible.
31 Figure 5.1-2 Reproduced to be more legible.
31 Figure 5.3-1 A Reproduced to be more legible.
31 Figure 5.3-1B Reproduced to be more legible.
31 Section 5.3.1 Clarify non-use of personnel barrier in shielding 28 calculations.
Figure 5.3-2A Reproduced to be more legible.
31 Figure 5.3-2B Reproduced to be more legible.
31 Figure 5.4-1 Reproduced to be more legible.
31 Chapter 6 The entire chapter was revised to incorporate the 29 results of the re-performed criticality calculations.
8.1.3.2 Typo was corrected.
24
)
8.1.3.3 Revised the procedure for pre-shipment leak 22 and 23 testing.
8.1.4.3 Added a statement regarding the sealing of the 8
impact limiter.
j Acceptance criterion for honeycomb material.
j Figure 8.1-1 Reproduced to be more legible.
31 8.2.7 Added a discussion of the fabrication and 8
periodic inspections of the impact limiter.
1 i
2
i ENCLOSURE 5 REPLACEMENT PAGES FOR SAFETY ANALYSIS REPORT, REVISION C (REDACTED /NON-PROPRIETARY) i i
h l
l L.
'BNFL Fu:1 Solutions BFS/NRC 99-083, Enclosure 5 LIST OF INSTRUCTIONS REMOVE PAGE(S)
INSERT PAGE(S)
Title page Title page iii through xv i through xiv xv through xvii 1-7 through 1-9 1-7 through 1-9a 1-19 through 1-26 1-19 through 1-26 Drawing SAR-71-002, Sht.1 of 6, Rev. O Drawing SAR-71-002, Sht. I of 6, Rev. 2 Drawing SAR-71-003, Sht.1 of 2, Rev. O Drawing SAR-71-003, Sht.1 of 2, Rev.1 Drawing SAR-71-004, Sht.1 of 8, Rev. O Drawing SAR-71-004, Sht. I of 8, Rev.1 Drawing SAR-71-005, Sht.1 of 12, Rev. O Drawing SAR-71-005, Sht.1 of 12, Rev. 2 2-15-a 2-19 2-19 2-46 2-46 2-61 2-61 2-87 2-87 2-134 2-134 2-135-b 2-135-b 2-135-c 2-135 -c 2-135-e 2-135-e 2-135-f 2-135-f 2-156 2-156 3-4 through 3-8 3-4 through 3-8 3-10 3-10 l
3-18 through 3-20 3-18 through 3-20 4-1 4-1 4-5 j
l 5-6 5-6 l
5-7 5-7 l
5-23 5-23 l
5-24 5-24 5-27 5-27 5-28 5-28 5-29 5-29 5-45 5-45 6-1 through 6-38 6-1 through 6-52 8-4 8-4 8-5 8-5 8-7 through 8-11 8-7 through 8-11 8-15 8-15 1
I